What is EDGAR and DFSCA?
Part 86, the Drug and Alcohol Abuse Prevention Regulations (DFSCA), (Education Department General Administrative Regulations [EDGAR]), requires that, as a condition of receiving funds or any other form of financial assistance under any federal program, an institution of higher education (IHE) (1) must certify that it has adopted and implemented a program to prevent the unlawful possession, use, or distribution of illicit drugs and alcohol by students and employees. If audited, failure to comply with the Drug and Alcohol Abuse Prevention Regulations may cause an institution to forfeit eligibility for federal funding.(2) See link: http://www.higheredcenter.org/mandates/dfsca
In compliance with these regulations JMU just published their Biennial Report Spring 2011 (see full report at ) http://www.docstoc.com/docs/document-preview.aspx?doc_id=71997619
First let me say that this report is very well organized and is the best compilation in one document of all of the efforts that JMU is engaged in to deal with the alcohol issue at JMU. Much of the data in the Appendixes of the report have appeared in previous post on this blog. Of concern to me is that a careful reading of the report shows that the efforts that JMU has made are not effective. Of greater concern is that JMU is aware from the data that the efforts are not effective and the JMU plan is to do more of what has been demonstrated to be not effective. Even when examining a program like BASICS, which has good effectiveness demonstrated in the literature, JMU failed to follow through and collect the data to show if JMU's implementation of BASICS had a positive outcome. Below are some highlights.
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The DFSCA regulations have several minimum requirements, some of them are: The law further requires an institution of higher education to conduct a biennial review of its program:
- To determine its effectiveness and implement changes if they are needed
- To ensure that the sanctions developed are enforced consistently
On page 15 of JMU's report it states:
Education
Effecting positive behavior change among college students regarding alcohol use and abuse is challenging. Over the years, colleges and universities including JMU have spent significant financial resources and appropriated many hours of staff time addressing this issue.
Despite concentrated and continuous efforts to educate students regarding the potential negative consequences of irresponsible use of alcohol, change in behavior has been slow and traditional educational strategies have often proven to be ineffective. There are no simple answers to this complex issue. Educating college students about responsible alcohol use is challenging in general and it is further complicated by the fact that most of our students are underage. Additionally, having awareness and knowledge about a subject does not automatically lead to behavior change; this generation of college students has had extensive exposure to educational campaigns regarding alcohol and drug abuse long before arriving on campus. Even though the task of educating students about making responsible choices about alcohol use is daunting, it is critical that we continue to seek out and implement new programs and approaches that have been proven to be effective. To this end, we propose the following actions:
• SAUP will increase the visibility of and support for the office of Substance Abuse Prevention’s comprehensive work in addressing the problem by
continuing and expanding the universal, targeted and indicated approaches to
educating students about decisions regarding alcohol use. Routine and ongoing evaluation and assessment will be conducted to ensure the implementation of the most effective strategies.
• SAUP will increase the visibility of and support for referral programs utilized for students who have received alcohol sanctions or who self-refer.
The BASICS (Brief Alcohol Screening and Intervention for College Students) program, which has been shown to produce significant positive behavior change,
will be expanded to meet the needs of students identified as having problems with alcohol use. Also, the educational component for judicial sanctions involving alcohol will be maintained.
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- The data in the literature shows that the educational programs approach is not effective in creating behavior change. The JMU CORE data (see earlier post and Appendix B of the report) actually shows that alcohol behavior at JMU is consistently getting worse from year to year. Yet JMU's plan is to continue and expand educational programs that they know don't work to change behavior.
APPENDIX A: SAUP Vision and Strategic Plan 2014, Goal 1: Performance Indicator 1.3 has one of the few measurable criteria for evaluation of JUM's efforts to deal with the alcohol issue. It says:
"Students will report a decrease in negative behaviors associated with alcohol use as report by the Core Alcohol & Other Drug Survey, the ACHA survey and other campus reports."
- The CORE data to date show an increase in negative behaviors associated with alcohol use
- The literature shows the BASICS program to be effective. However the JMU data shows that JMU did a very poor job of data collection and therefore can say very little about the effectiveness of the BASICS program as implemented by JMU. For example in Appendix C
- Of the 65 students in the sample only 19 completed all of the post test.
- However, the difference in participant mean peak BAC from post-test 1 to post-test 2 was not significant, t(18) = .43, p = .67.
- However, differences in participant mean total AUDIT score were not significant from pre- to post-test 1, t(18) = 1.74, p = .10, and post-test 1 to post-test 2, t(18) = 1.62, p = .12.
- However, these differences are only statistically significant for participant self-reported drink quantity and peak BAC from pre- to post-test 1 andpre- to post-test 2. Differences in participant mean total AUDIT and RAPI scores are only significant from pre- to post-test 2.
- As noted previously, the analyses are exploratory in nature and the results should be interpreted with caution.
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JMU presents some very detailed information on it's statistical analysis. I am not an expert in statistics. But the failure to collect post test data on 2/3 of your sample and the results being "not significant" and the "results should be interpreted with caution" all sound to me like a poorly conducted study of the effectiveness of the BASICS program as implemented by JMU.
The Dept of Education Higher Education Center, post A Guide for University and College Administrators for complying with the requirements of the EDGAR report. (see link
http://www.higheredcenter.org/files/product/dfscr.pdf )
Part of the guidelines state:
Measuring Policy and Program Effectiveness
To strengthen the quality of prevention programs implemented with funds from the Office of Safe and
Drug-Free Schools, the Department established a set of principles of effectiveness in 1998, since incorporated into the No Child Left Behind Act of 2001 (Title IV—Section 4115). A subset of the principles of effectiveness that are most applicable to IHEs can be summed up as follows:
- Design programs based on a thorough needs assessment of objective data.
- Establish a set of measurable goals and objectives linked to identified needs.
- Implement prevention activities that research or evaluation have shown to be effective in preventing high-risk drinking or violent behavior.
- Use evaluation results to refine, improve, and strengthen the program and refine goals and objectives as appropriate.
Basic to the success of any prevention program is the need to ensure the widespread involvement of key
stakeholders, including students, faculty members, alumni, and community members, in the program’s
design and implementation. Leadership from college and university presidents and other senior administrators
is key to institutionalizing prevention as a priority on
campus.
In summary, I see JMU as having demonstrated the ineffectiveness of it's efforts and as not implementing the changes that are needed and therefore failing to meet the requirements of the law "to determine its effectiveness and implement changes if they are needed" one of the minimum requirements noted above.
